name, symbols or logos of their organization or to define its objectives and activities.286 In some participating States, authorities have reportedly censored NGO statutes by requiring the removal of unwanted words, symbols, activities or objectives related to certain human rights issues or minority groups, or have denied registration if a title or symbol of an organization contains a name of a minority group. According to the Special Rapporteur on the situation of human rights defenders, certain governments apply such measures in order to “filter those groups that are critical of government policies”287 and significantly restrict their activities. 201. As set out in the FCNM, freedom of association and the right to participate in the activities of NGOs also apply to minority communities. Restrictions must not be imposed arbitrarily, but only insofar as they are permitted by international law. In its jurisprudence, the ECtHR has emphasized that freedom of association is particularly important for persons belonging to minorities, including national and ethnic minorities.288 While recognizing that certain restrictions on the right to freedom of association may be permissible if these are prescribed by law and necessary in a democratic society in the interest of one of the grounds enumerated in the Convention, the ECtHR has held in its case law that a refusal to register an association solely to prevent the spread of the idea that there is an ethnic minority on the territory of a state whose rights are not fully respected is in violation of Article 11 of 286  In Communication No. 1478/2006, Kungurov v. Uzbekistan, of 17 March 2006, the UN Human Rights Committee considered the case concerning the refusal of the authorities to register the non-governmental organization “Democracy and Rights” for not conforming with two requirements of domestic law – namely, that the association concerned should not engage in human rights activity that any official body is engaged in and should be present in every region of Uzbekistan to be considered a “national” NGO as opposed to a local NGO. The Committee held that the State Party failed to advance any argument as to why it would be necessary in a democratic society to condition the registration of an association based on the scope of its human rights activities to undefined issues not covered by state organs or on the existence of regional branches of the association (para. 8.5). 287  A/64/226, 4 August 2009, para. 60. 288  See Gorzelik and others v. Poland, Application no. 44158/98, 17 February 2004, para. 93. The case related to the refusal of the authorities to grant registration to an association that characterized itself as an organization of the Silesian “national minority”. While the Court found that the interference in that case could not be considered disproportionate given the special status and privileges the registration of the association as a legal entity would have created under electoral laws, it emphasized that forming an association in order to express and promote its identity may be instrumental in helping a minority to preserve and uphold its rights. In doing so, the Court recalled the Preamble of the Council of Europe Framework Convention for the Protection of National Minorities, which sets out that “a pluralist and genuinely democratic society should not only respect the ethnic, cultural, linguistic and religious identity of each person belonging to a national minority, but also create appropriate conditions enabling them to express, preserve and develop this identity”. Guidelines on the Protection of Human Rights Defenders 93